It was just late last week that a federal judge denied former Northeast Florida Democratic Congresswoman Corrine Brown’s motion to delay her sentencing hearing- and now, her defense is making a second attempt.

The second motion to continue sentencing hearing and motion to reconsider/rehear order denying continuance filed Tuesday rely heavily on the Presentence Report, which the defense says does not present “sufficient information” in a number of areas. The PSR was put together by Brown’s Probation Officer and submitted on October 12th, according to court records.

The PSR itself is not considered a public document, so it’s exact contents are not clear, however this new motion indicates the PSR recommends “a significant and lengthy prison time” for Brown. Brown’s defense is seeking probation.

One area the PSR “fails to present sufficient information”, according to the defense, is when considering Brown’s medical and physical condition. The motion says Brown is still undergoing testing and evaluation, and that “additional suspected medical conditions have not yet been fully diagnosed”. The motion further says those anticipated findings will likely be “significant”. Brown’s mental and emotional condition is also not fully examined in the PSR, according to the motion. The defense says she is “undergoing evaluative treatment regarding the implications of certain abnormalities” in those areas.

The motion also calls back to the prior arguments from the defense, which is that damage Brown suffered from Hurricane Irma inhibits their ability to mount a defense. Unlike the prior motion for a continuance- which was ultimately denied by a judge, in part because of a lack of specifics- this motion details the ways in which the storm affected their case building efforts. Brown’s defense says documents that are “indispensable” to showing her history of charitable works and good service prior to her offenses were destroyed. They believe that history can be recreated through interviews, but need more time to work through that. The motion further says the damage to Brown’s home- which the defense says FEMA has determined makes the home uninhabitable- is being mitigated, but Brown needs more time to see that through in order to “protect the investment in the property”.

Finally, the motion argues the PSR doesn’t have enough information about the statistical analysis and comparison of United States Sentencing Commission data on comparable sentences nationwide.

In all, the defense argues they need more time to investigate and examine any of this information they believe to be missing, so that they can be adequately prepared for sentencing.

The defense is asking the sentencing be continued to February. It’s currently scheduled for November 16th- a date that was set back in August, when their motions for a new trial and for an acquittal were denied. The motion indicates that the US Attorney’s Office objects to any continuance, and the judge has given the government until 5PM Thursday to formally respond.